Justia Education Law Opinion Summaries

A sixth-grade student with behavioral disabilities, X.M., attended Mount Pleasant Public Schools under an Individualized Education Plan that allowed him to use a breakroom to manage stress. In the fall of 2021, after a student reported that X.M. had brought a gun to school, school officials, including special-education teacher Jason Russell, searched X.M.’s locker and questioned him, but found nothing. The next day, after X.M. made a comment about not having his gun at school, officials again searched his belongings. According to X.M., Russell then ordered him to pull down his trousers and lift his shirt in a search for a gun. Days later, after X.M. was suspended for violence, he claimed Russell locked him in the breakroom for over 20 minutes.Cheyenne Johnson, X.M.’s mother, sued Russell, the school district, and other officials, alleging violations of X.M.’s constitutional rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Russell, denying him qualified immunity on the Fourth Amendment claims. The district court found that disputed facts—specifically, whether Russell conducted a strip search and locked X.M. in the breakroom—required a jury’s determination.The United States Court of Appeals for the Sixth Circuit reviewed the case on interlocutory appeal. The court held that, even accepting X.M.’s version of events, Russell did not violate clearly established Fourth Amendment rights. The court found that Russell’s search was justified at its inception and not clearly excessive in scope given the suspicion of a gun. It also concluded that it was not clearly established that locking a student in a breakroom for 20 minutes under these circumstances constituted an unreasonable seizure. The Sixth Circuit reversed the district court’s denial of qualified immunity and remanded with instructions to dismiss the Fourth Amendment claims against Russell. View "Johnson v. Mount Pleasant Public Schools" on Justia Law

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

A student, C.M., experienced repeated racial harassment by peers while attending public school in Michigan, including being subjected to racial slurs, threats, and physical assault. The harassment occurred during her sixth, seventh, and ninth grades, prompting her to transfer to another school district in her freshman year. C.M. and her parents alleged that the school district and its officials failed to adequately respond to her complaints, asserting violations of federal law (Title VI of the Civil Rights Act and the Equal Protection Clause) and Michigan’s Elliott-Larsen Civil Rights Act.The United States District Court for the Eastern District of Michigan reviewed the case and granted summary judgment in favor of the school district and its officials. The district court found that, even when viewing the facts in the light most favorable to C.M., the school’s responses to the reported incidents did not amount to deliberate indifference under the applicable legal standards. C.M. appealed this decision to the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court assumed, without deciding, that deliberate indifference claims are cognizable under Title VI for student-on-student racial harassment. Applying the deliberate indifference standard, the court held that the school’s responses to each reported incident were not clearly unreasonable and reflected good faith efforts, including investigations, disciplinary actions, and proactive measures. The court concluded that C.M. failed to establish deliberate indifference, and therefore her claims under Title VI, the Equal Protection Clause, and the Elliott-Larsen Civil Rights Act could not succeed. The judgment of the district court was affirmed. View "Malick v. Croswell-Lexington Dist. Schs." on Justia Law

A group of parents sued their local public school district and the State of Michigan, alleging that their children were denied essential special-education services. The parents claimed that the school district failed to provide promised services, such as full-time aides and speech therapy, and that the State failed to supervise the district adequately. The parents sought damages under the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and injunctive relief under the Individuals with Disabilities Education Act (IDEA), ADA, and Rehabilitation Act.The United States District Court for the Eastern District of Michigan denied the State's motion to dismiss, holding that the ADA abrogated the State's sovereign immunity under the Fourteenth Amendment. The State then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that the parents failed to state a claim against the State under Title II of the ADA. The court explained that Title II allows lawsuits against a public entity for its own actions, not for the actions of another government entity. In this case, the school district, not the State, was responsible for the alleged denial of services. The court also noted that the State had already taken corrective actions against the school district and that the parents' claims of the State's failure to supervise were too conclusory to proceed. Therefore, the State was entitled to sovereign immunity, and the parents' ADA claim against the State was dismissed. View "Y.A. v. Hamtramck Public Schools" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

William A., a dyslexic student, graduated from high school with a 3.4 GPA but was unable to read. His parents filed a complaint under the Individuals with Disabilities Education Act (IDEA), claiming the school failed to provide him with a free appropriate public education (FAPE). The school had developed an individualized education plan (IEP) for William, which included language therapy and one-on-one instruction, but he made no progress in reading fluency throughout middle and high school. His parents eventually arranged for private tutoring, which helped him make some progress.An administrative law judge (ALJ) held a due-process hearing and found that the school had violated William's right to a FAPE under the IDEA. The ALJ ordered the school to provide 888 hours of dyslexia tutoring. William's parents then sought an order in federal court for the tutoring to be provided by a specific tutor, Dr. McAfee. The school counterclaimed, seeking reversal of the ALJ's order. The district court, applying a "modified de novo" standard of review, affirmed the ALJ's findings and ordered the same relief but denied the request for Dr. McAfee specifically.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the school had not provided William with a FAPE, as his IEPs focused on fluency rather than foundational reading skills necessary for him to learn to read. The court noted that William's accommodations masked his inability to read rather than addressing it. The court affirmed the district court's judgment, holding that the school failed to provide an education tailored to William's unique needs, as required by the IDEA. View "William A. v. Clarksville-Montgomery County School System" on Justia Law

A preliminary injunction required the Highland School District Board to treat an 11-year old transgender special-needs student as a female and permit her to use the girls’ restroom. Highland moved to stay the injunction pending appeal and to file an appendix under seal. The Sixth Circuit granted the motion to file under seal only with respect to four exhibits that were filed under seal in the trial court. In denying a stay, the court noted the girl’s personal circumstances—her young age, mental health history, and unique vulnerabilities—and that her use of the girls’ restroom for over six weeks has greatly alleviated her distress. Maintaining the status quo in this case will protect the girl from the harm that would befall her if the injunction is stayed. Public interest weights strongly against a stay of the injunction; the protection of constitutional and civil rights is always in the public interest. View "Board of Education of Highland School v. Doe" on Justia Law

J.G.’s mother, Gohl, enrolled J.G. (age 3) in the Webster School Moderate Cognitive Impairment Program. During the year, his teacher,Turbiak, a 12-year special education teacher, faced criticism that she was overly harsh. It was reported that she pushed on children’s shoulders, once force-fed a gagging and crying student, and lifted children by one arm. During a meeting with Principal Moore, Turbiak admitted that she was “stressed out.” Although Moore told Turbiak not to do so, Turbiak called a meeting to find out who had complained. Turbiak’s co-workers returned to Moore, fearing retaliation. Turbiak was sent home for a few days and warned to be more professional, or face disciplinary action. The letter did not accuse Turbiak of abusing students. For four months, no one reported any problems. Then a social worker saw Turbiak “grab [J.G.] by the top of his head and jerk it back quite aggressively.” Turbiak claimed she was using a “redirecting” technique to focus J.G.’s attention after he threw a toy. A special education teacher familiar with this technique thought this sounded reasonable and returned Turbiak to her classroom. After a subsequent investigation, the district placed Turbiak on administrative leave. Gohl sued on J.G.’s behalf. The Sixth Circuit affirmed summary judgment in favor of the defendants; Gohl did not sufficiently allege violation of the Constitution, the Americans with Disabilities Act, or the Rehabilitation Act. View "Gohl v. Livonia Pub. Schs." on Justia Law

Binno, a legally blind individual, unsuccessfully applied for admission to law schools. He then filed suit against the American Bar Association (ABA), under the Americans with Disabilities Act (ADA), claiming that his lack of success was due to a discriminatory admissions test “mandated” by the ABA. Thar examination, the Law School Admissions Test (LSAT) is used by nearly all U.S. law schools. Binno claimed that the LSAT's questions have a discriminatory effect on the blind and visually impaired because a quarter of those questions “require spatial reasoning and visual diagramming for successful completion.” The Sixth Circuit affirmed dismissal of the complaint, concluding that Binno does not have standing to sue the ABA because his injury was not caused by the ABA and because it is unlikely that his injury would be redressed by a favorable decision against the ABA. The LSAT is written, administered, and scored by the Law School Admission Council (LSAC), which is not part of the ABA. The LSAC provides ADA accommodations (42 U.S.C. 12189) for persons with disabilities who wish to take the LSAT. The law schools to which he applied, not the ABA, determine what weight, if any, to give Binno’s LSAT score. View "Binno v. Am. Bar Ass'n" on Justia Law